Pakistan: Mandatory e-Invoicing for Large Taxpayers
As of June 1, 2025, all large taxpayer enterprises must have their accounting, invoicing, and point-of-sale (POS) systems integrated with the Federal Board of Revenue (FBR) of Pakistan. This requirement is established in the 2024 Finance Bill and official document F. No. 1(141) ST-L&P/2025/55105-R, which confirms the mandatory implementation of e-invoicing.
Non-corporate taxpayers must register with the FBR before July 1, 2025.
Mandatory Electronic Invoicing in Pakistan
June 1, 2025, marks a turning point in Pakistan’s tax system, as mandatory electronic invoicing comes into force for all large taxpayers. This measure, driven by the Federal Board of Revenue (FBR), is part of a broader government initiative to digitize tax processes, strengthen tax oversight, and reduce tax evasion.
The requirement is formalized in the 2024 Finance Bill and official notification F. No. 1(141) ST-L&P/2025/55105-R, submitted to the National Assembly. Both documents confirm that companies classified as large taxpayers are required to fully integrate their accounting, invoicing, and POS systems with the FBR’s electronic infrastructure for real-time transmission of electronic invoices.
Currently, e-Invoicing in Pakistan applies to the sale and purchase of goods, not services. However, in some regions like Islamabad, both goods and services are subject to mandatory e-Invoicing.
Meanwhile, non-corporate taxpayers (such as sole proprietors, simple businesses, or other entities not registered such as legal persons) must register with the FBR by July 1, 2025. While they are not required to implement full system integration by the same date as large taxpayers, registration is a necessary first step for future phases of the e-invoicing program.
How Does E-Invoicing Work in Pakistan?
The FBR will implement an electronic invoice validation system.
Integration with the FBR requires companies to adopt technology solutions compatible with the government’s central platform, capable of:
- Issuing e-Invoices that meet all legal requirements. All sales or supplies must be conducted through the e-Invoicing system, generating a real-time verifiable e-Invoice for each taxable supply.
- Reporting invoices in real time or near real time, ensuring proper registration and traceability.
- Electronically storing and archiving invoices in compliance with the technical specifications issued by the FBR, for a period of six years.
The Start of E-Invoicing
On November 10, 2023, the Federal Board of Revenue (FBR) of Pakistan announced changes and requirements to the e-Invoicing system, which initially applies only to certain consumer goods. Fast-moving consumer goods are defined as products sold at retail to meet consumers’ daily needs (excluding durable goods).
In December 2023, the FBR published a notification specifying that manufacturers, importers, wholesalers, and distributors of FMCGs must issue sales tax e-invoices through an FBR-approved system. These selected taxpayers were required to start issuing e-invoices from February 1, 2024, via the government’s central platform. The Pakistani government refers to these taxpayers as “integrated suppliers.”
Since April 2024, importers and taxpayers in the FMCG sector have been obligated to comply with the e-Invoicing regime established by the FBR. This measure is part of the government’s broader effort to enhance tax transparency, combat tax evasion, and modernize tax administration.
The requirement means that all commercial transactions conducted by these taxpayers must be reported to the FBR in real time via compatible electronic systems. This includes issuing digital invoices, immediate validation by the FBR, and secure archiving on FBR-approved platforms.
